https://www.taxtmi.com/caselaws?id=783650 Transfer pricing: corporate guarantee fee adjustment was deleted by directing the TPO to follow binding coordinate bench orders in the taxpayer's own case. Disallowance under s.14A r.w. Rule 8D(2)(iii) was deleted as covered by earlier years' Tribunal decisions. For MAT, s.14A disallowance was held not addable to book profits under s.115JB because the Explanation does not specify s.14A, hence excluded. Payment to an employees' school within the business ????? was allowable u/s 37(1) as employee-welfare/commercial expediency, so disallowance was deleted. Alleged short TDS deduction addition was deleted as the taxpayer proved no short deduction. CER transfer/cancellation receipts were held capital and excluded from normal income and MAT. Additional deductions/claims (s.10A(1A), s.35DDA, s.80IA, additional depreciation) were allowed/ remitted for AO verification; book-profit/TDS-TCS credits issues were remanded. Weighted deduction u/s 35(2AB) was allowed in full despite DSIR Form 3CL limitation. en-us Fri, 12 Dec 2025 00:00:00 +0530 Thu, 18 Dec 2025 15:51:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783650 Transfer pricing: corporate guarantee fee adjustment was deleted by directing the TPO to follow binding coordinate bench orders in the taxpayer's own case. Disallowance under s.14A r.w. Rule 8D(2)(iii) was deleted as covered by earlier years' Tribunal decisions. For MAT, s.14A disallowance was held not addable to book profits under s.115JB because the Explanation does not specify s.14A, hence excluded. Payment to an employees' school within the business ????? was allowable u/s 37(1) as employee-welfare/commercial expediency, so disallowance was deleted. Alleged short TDS deduction addition was deleted as the taxpayer proved no short deduction. CER transfer/cancellation receipts were held capital and excluded from normal income and MAT. Additional deductions/claims (s.10A(1A), s.35DDA, s.80IA, additional depreciation) were allowed/ remitted for AO verification; book-profit/TDS-TCS credits issues were remanded. Weighted deduction u/s 35(2AB) was allowed in full despite DSIR Form 3CL limitation. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783650